SecProbe.io

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                         [IBT BANCORP, INC. LETTERHEAD]

BY FACSIMILE AND EDGAR
----------------------

June 13, 2005

Mr. Don Walker
Senior Assistant Chief Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Mail Stop 0408
Washington D.C. 20549

Dear Mr. Walker,

         I am writing  on behalf of IBT  Bancorp,  Inc.  (the  "Registrant")  in
response to the staff's  letter of comment dated June 3, 2005. Our responses are
numbered so as to correspond with the numbering in the comment letter.

Form 10-K
---------

Nonperforming and Problem Assets - page 8
-----------------------------------------

1.       The increase of $2.9 million in mortgage loans past due 90 days or more
         consisted  of a  commercial  real  estate  loan in the  amount  of $2.6
         million secured by a country club and a $355,000 commercial real estate
         loan secured by a retail store.

Analysis of the Allowance for Loan Losses - page 10
---------------------------------------------------

2.       The gross amounts of charge-offs and recoveries by loan type  for  2004
         and 2003 are as follows:

         2004               Charge-offs             Recoveries           Net
         ----               -----------             ----------           ---
         Commercial        $      7,484              $  45,179      $    37,695
         Mortgage             1,203,959                      0       (1,203,959)
         Installment            127,306                  2,382         (124,924)

         2003
         ----
         Commercial        $    148,497              $  35,584      $  (112,913)
         Mortgage                10,954                      0          (10,954)
         Installment             83,510                 18,890          (64,620)

         In future  filings,  the  Registrant  will present the gross amounts of
         charge-offs  and  recoveries  for each loan category in the Analysis of
         the Allowance for Loan Losses.

                                     Page 1
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Exhibit 13
----------

2004 Annual Report
------------------

Results of Operations
---------------------

Provision for Loan Losses - page 5
----------------------------------

3.       The $1.2  million  increase  in mortgage  charge-offs  for 2004 was due
         primarily to a $777,916  charge-off  of a  commercial  real estate loan
         that was  secured  by a motel  as well as a  $409,651  charge-off  of a
         commercial real estate loan secured by a multi-family  housing unit. In
         determining  the  amount of the  charge-offs  in these  instances,  the
         Registrant considered the appraised value of the properties relative to
         the loan  balance and charged off the amount by which the loan  balance
         exceeded 90% of the appraised value.

4.       With the exception of the two commercial  real estate loans  referenced
         in response to Comment  #3, the overall  quality of the loan  portfolio
         has not changed  significantly.  We are  beginning  to  originate  more
         asset-based  loans and this will impact the portfolio in the future. In
         addition,  the dollar  amount of the  charge-offs  served to reduce the
         loan loss  reserve.  Our  methodology  concerning  the  adequacy of the
         reserve is to analyze the portfolio  using a five-year  rolling average
         charge  off/recovery  rate,  adjusted  for  non-qualitative  items.  We
         believe this method  complies with GAAP, and our auditors  concur.  The
         December  31,  2004  general  ledger  balance  was  within  10%  of the
         calculated adequate balance, which is within our prescribed policy.

5.       The Registrant's  primary federal regulator is the FDIC. The Registrant
         is not party to any formal  agreement  requiring  it to make changes in
         its reserve for loan losses. In their most recent examination, the FDIC
         indicated  that although it agreed with our  methodology of calculating
         the necessary balance needed in the loan loss reserve, it believed that
         the balance of the reserve was marginally  adequate.  The FDIC strongly
         encouraged  us to increase the reserve to a level  consistent  with our
         peers,  which is between 1% and 1.25%. We indicated to the FDIC that we
         would  endeavor  to increase  the balance in the loss  reserve so as to
         achieve a ratio of loss reserve to loans of closer to 1%.

Form 10-Q
---------

Provision for Loan Losses - page 8
----------------------------------

6.       The effect of the large loan  losses on the loan loss  reserve  was not
         deferred  until the first quarter of 2005. As  previously  stated,  the
         balance in the loss  reserve at December  31, 2004 was deemed  adequate
         according  to the  methodology  used to  calculate  the adequacy of the
         reserve.  The  increased  provision  for loan  losses  during the first
         quarter of 2005 was  prompted  by an FDIC  examination  that

                                     Page 2

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         concluded  during the first quarter. As previously stated, although the
         regulators  indicated  that they agreed with the  methodology we use to
         calculate the adequacy  of our loan loss reserve they were unhappy that
         the general ledger balance  as of December 31, 2004 did not result in a
         ratio of loan loss reserve to total loans approaching 1%.

7.       In response to the comment  please note that the  statement in the Form
         10-Q is incorrect in that it states that several large loan charge-offs
         occurred  during  the  fourth  quarter.  In fact,  only one large  loan
         charge-off  occurred  during the fourth quarter and is detailed  below.
         The Form  10-Q will be  amended  accordingly  once we have the  staff's
         assurance that no further amendments will be required.
         The details of the large  charge-off  that  occurred  during the fourth
         quarter is as follows:  The borrower is a real estate  investor who, we
         believe,  became over extended.  The original  principal balance of the
         loan was $488,000.  The loan was originated on July 31, 2002 at a fixed
         rate of 7%. Because of his poor business  acumen and absentee  landlord
         status,  the  borrower  allowed the property to become  run-down.  As a
         result  tenants  began  leaving,  resulting  in a decline in cash flow,
         which  resulted in an  inability to make timely  mortgage  payments and
         which caused  utilities to be shut off. Because of the condition of the
         property an appraisal indicated a market value of $100,000, $90,000 was
         recorded  as  Real  Estate  Owned  and  $409,651,  which  included  the
         remaining  principal  and other costs  associated  with this loan,  was
         charged off in December 2004.

We acknowledge that:

|_|  the Company is responsible  for the adequacy and accuracy of the disclosure
     in the filing;
|_|  staff  comments or changes to disclosure  in response to staff  comments do
     not  foreclose  the  Commission  from taking any action with respect to the
     filing; and
|_|  the company may not assert  staff  comments as a defense in any  proceeding
     initiated by the Commission or any person under the federal securities laws
     of the United States.

We are  pleased to be able to provide  the  information  you  requested.  If you
require anything further regarding this matter, please do not hesitate to call.

Sincerely,

/s/Charles G. Urtin

Charles G. Urtin
President and CEO

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